Steve Henley, Appellee v. State of Tennessee, Appellant

Summary

The Tennessee Supreme Court reversed the Court of Criminal Appeals and reinstated the trial court's denial of Steve Henley's post-conviction petition, holding that the evidence supported the finding that Henley received effective assistance of counsel at the sentencing phase of his capital trial. On the witness-preparation claim, the court found no Strickland prejudice because the grandmother's and petitioner's testimony had already placed substantially all favorable mitigation before the jury, the uncalled relatives' proffered testimony was general, cumulative, or affirmatively harmful (revealing drug and alcohol use), the heinous-aggravator proof was strong, and the juror's affidavit about the mother's refusal to testify was inadmissible under Tenn. R. Evid. 606(b). On the mental-health claim, the court held counsel was not deficient because Henley's own consistent denials of intoxication and drug use and his weather-based explanation for his farming failures gave counsel reason to believe such investigation would be fruitless or harmful. Justices Reid and Birch dissented, contending that counsel's investigation and preparation at sentencing were constitutionally deficient and prejudicial and that Henley was entitled to a new sentencing hearing.